No it isn't. It's an entirely new mould that doesn't share a single part in common with any other Prime figure.

It doesn't even have the same transformation, it's about as far from a retool as you can get.

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I thought it was confirmed that there were core peices that eren't changed? Oh well, if you say so. I don't have the pics up at the moment, but I could've sworn that the legs and shoulders (not arms) tf'ed the same.

The transfomation's are certainly close. Close enough to mistake as a retool. With the lower arms and some of the chest being the only major differences.

Yeah, we know there's a 2-pack, but I'm pretty sure there's been no official word yet as to what's in it.

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We were told that the 2-pack would be of a Voyager and a Deluxe. Beyond that nothing's official, but extremely likely that it'll be this battle damaged Prime and a battle damaged Megatron. Kinda off-topic, but, I personally hope that we get toy versions of the Allspark, Megatron's head, and Megatron's hand. It would be an easy way to introduce figures of the human characters.